New Regulations Require Federal Contractors to Ask Employees if They Have a Disability

Nearly a quarter of the U.S. workforce will soon have to answer a personal question from the boss: Are you disabled?

U.S. regulations going into effect next week require for the first time that federal contractors—a group that includes
Boeing
Co.
, Dell Inc. and
AT&T
Inc.,
among some 40,000 others—ask their employees if they have a disability.

Those that don't employ a minimum of 7% disabled workers, or can't prove they are taking steps to achieve that goal, could face penalties and, in the most extreme cases, the loss of their contracts, according to a government official. The target applies to contractors with 50 or more employees or more than $50,000 in government work.

The Labor Department issued the rules as part of an effort to reduce the high jobless rate among people with disabilities; a similar initiative calls for an 8% hiring target for military veterans. Government officials say the targets are "aspirational" and not rigid quotas.

ENLARGE

Federal contractors, like Boeing, are required to ask workers if they have a disability. Pictured, a Boeing plant.
Reuters

Employees aren't required to disclose their specific impairment.

Still, the rules have left contractors anxious about stepping on legal minefields. The Americans With Disabilities Act, or ADA, forbids companies to gather information on a worker's disability status, since the disclosures could lead to discrimination. The Equal Employment Opportunity Commission has made an exception so that federal contractors can comply with the new rules.

Now, these companies face a dilemma. If not enough workers come forward to self-identify as disabled, company recruiters will need to retool their hiring practices to show they are trying to meet the targets. But employees may be uneasy disclosing health-related information to their bosses.

"The word disability means you're not able to do something. People don't want to be perceived that way," said Joe Gavigan, a 37-year-old engineer at contractor GE Aviation. Mr. Gavigan was paralyzed in 1999 while a student at the U.S. Air Force Academy and later co-founded an employee resource group for individuals with disabilities at the
General Electric
Co.
unit.

"You don't want your boss to see you as being limited in your capability," he said.

A 2008 amendment to the ADA expands the definition of disability. Alongside long-recognized impairments like blindness, the list now includes conditions such as cancer, diabetes, major depression, epilepsy and obsessive-compulsive disorder. Under that broader definition, many large companies may meet or surpass the 7% target already, said
Daniel Yager,
president of the HR Policy Association.

The number of disabled workers will be accurately captured only if employees are willing to raise their hands and be counted.

"A lot of employees don't see those issues as being properly categorized as disabilities. They see it as something they've learned to live with," said
Chris Miller,
vice president of employee relations at electric-power utility
Southern
Co.
, an Atlanta-based contractor with 26,000 workers.

At Intuitive Research and Technology Corp. in Huntsville, Ala., an engineering firm with contracts from the Department of Defense, 19% of workers have disabilities, said
Juanita Phillips,
director of human resources. Intuitive recruits and sponsors classes and lecture series at the nearby Redstone Arsenal, a U.S. Army post. The partnership helps Intuitive meet two compliance goals at once by hiring veterans, some of whom have disabilities because of military service-related injuries.

Still, Ms. Phillips said, "We have people who are visibly handicapped that choose not to self-identify as such."

The new guidelines were pushed in part by disability advocates, who say that previous government rules were ineffective at finding jobs for veterans and victims of illness or accident, even while technology has expanded the categories of jobs they are able to perform.

Individuals with disabilities had an unemployment rate of 14.3% in February, nearly twice that of the nondisabled population. They are more than three times less likely than other workers to be in the labor force at all, a figure that has hardly changed over the last five years, according to the Bureau of Labor Statistics.

But even some of the rule's proponents admit that a groundswell of hiring from that pool is unlikely to occur if employers are able to prove that enough disabled workers are already on the payroll.

"Why have the target in there if it's not encouraging the hiring of people with disabilities?" asked
Mike Aitken,
vice president of government affairs at the Society for Human Resource Management.

Employers are gearing up now to implement the survey. Pharmaceutical giant
Merck
& Co., subject to the new rules because of supply contracts with the Department of Veterans Affairs and other agencies, plans to use its internal newsletters to address the changes with its 29,000 U.S. workers.

"We're putting our toe in the water on this and right now we're vetting" the materials, said
David Gonzales,
chief diversity officer. "Our focus is to make sure it's done in a very safe, private and confidential manner," he said, declining to provide further details.

While acknowledging that collecting the data is no easy task, Labor Department officials say the challenge itself will make workplaces more accommodating.

"It is a cultural change," said
Patricia Shiu,
director of the office that issued and oversees the rules. "Part of this is about creating an environment where people feel safe identifying that they are a person with a disability, that they won't be retaliated against if they ask for reasonable accommodations."

As a model, employers could look to their programs aimed at gays and lesbians, since sexual orientation, like most disabilities, isn't apparent without some form of self-disclosure, said
Jill Houghton,
executive director of the U.S. Business Leadership Network, a nonprofit group that assists companies with hiring people with disabilities.

The government has also established language for the self-identification surveys, which includes examples of qualified disabilities that workers may not realize fall under the ADA, such as cancer and major depression.

Great- you have a condition that meets the criteria for 'disability.' Maybe even enough so that you were actually on SS payments at some point, but you've overcome your disability or compensated to the extent that it doesn't affect your performance and is not noticeable. Congratulations- your hard work, treatment, physical rehab or therapy has succeeded, you are fully functional, and back in the real world. But wait- the government insists that your employer hires a percentage of people who admit to being disabled. So you are supposed to divulge private medical information? What this law really means is that your company must prove that they are hiring a percentage of disabled individuals that are willing to self-identify. There are a whole lot of good and honorable reasons why someone who has successfully overcome a disability (visible or not) is not interested in identifying as such.

What is the point of having federal contractors anymore then? Why not just have everyone work for the government? If we will all have to follow the same regulations regarding hiring practices, what's the point of having two different workforces?

The more regulations our government imposes on a system that was designed to be driven by market forces, the more it annihilates acquirable talent. So, we inject a percentage of disabled employees into a company that never had to conform to such regulations, thereby taking away that job from otherwise highly capable individuals. What are the effects to this company's competitive advantage now?

"Those that don't employ a minimum of 7% disabled workers, or can't prove they are taking steps to achieve that goal, could face penalties and, in the most extreme cases, the loss of their contracts, according to a government official."

Fines? Great. Even more fines for employers that are just trying to make a profit, you know, the thing that adds to our GDP but has become such a dirty word in this country. These are the providers of competitive US jobs. These are the people you want to fine for not conforming to 'target numbers?' I guess this is our idea of reducing unemployment. Brilliant.

This is a seemingly small step toward a planned economy. I am all for people with disabilities being gainfully employed; but let it be by the government. Congratulations Congress, you have ruined another aspect of a market economy.

When I first started the article, I thought maybe this could benefit my oldest child with Aspergers or Autism Spectrum Disorder. He recently started his first 'real' job now in his senior year of high school. (With the help of an excellent physician and therapist, hard work, and fantastic ! parenting he has accomplished goals and done things I never believed he would do.) But as I read on, I started thinking how many ways that could backfire in the workplace (or elsewhere.) Perhaps better for others to think that you are a little weird, different, or strange v. a diagnosis that could be used against you.

California finds and declares that crimes against elders dependent adults deserve special protection. I am 69, disabled Physician and ask for justice. I was drugged in attempt to kill me, change my Will and Trust and get me into bankruptcy court .I have been denied "Due Process of Law" for 4 years1) The embezzlers(a Pakistani National, Membership Chairman of a Muslim loyalist group and 3 others)opened 10 fraudulent Accounts at Private Bank of California (PBC.) 2) Judge Richard Neiter has stock in the PBC3)Individuals closely connected to the CEO of the PBC ( (Bradley Sharp, John Reitman,) have sold assets valued at greater than 80 million dollars.. All mortgages are fraudulent4) When I entered bankruptcy court I was drugged. I could not lift my head off the table and had no idea what I was doing.

Recently the Trustee and his attorneys concealed the theft of 14 retirement accounts embezzled through fraudulent accounts that violate the Patriot Act and Bank Secrecy act. The Medical Board of California has allowed the embezzlers to erect a website for reporting on me with Kimberly Wilson who has caused great damage.

Once the government begins to put pressure on employers to hire those with disabilities, it will also put pressure on those same employers not to dismiss employees with disabilities. And that means, as it has in the affirmative action arena, that employers will avoid hiring people in the "protected classes" if there is any chance that the person may not work out. As the parent of a young adult with an obvious physical disability (no survey questions needed), I do not want to see my son discriminated against. But even more, I do not want to see employers avoid hiring him, for fear they could not terminate him if he doesn't work out. Sometimes, even more than "protection", people just need a chance, and I don't see these new regulations as leading to that.

To all of those commentators who seem perplexed by my earlier statements, allow me to summarize my positions:

1) I support efforts by the government to encourage employers to offer jobs to the disabled.

2) As a former Libertarian who still gets a thrill when Ron Paul speaks, I prefer non-coercive measures, such as tax credits for private businesses to pay for workplace accommodations for their disabled employees.

3) More coercive measures should be applied "liberally" to non-profits and charitable organizations which fail to meet government-mandated quotas of disabled employees. Specifically, reduce their tax-exemption after the first violation, and revoke it completely if they persist in refusing to extend special considerations for the handicapped. If an organization wants a free ride on their taxes, they should prove that they are charitable, not just using their tax-exemption as an unfair advantage in competing with regular businesses which provide the same services. Tax-exempt charities should be exemplars of good intentions and good results. Otherwise, why should the rest of society continue to subsidize them?

That is a bizarre rule. I am a retired GE employee. I had cancer while at GE. I did not want anyone to think I was "disabled" because of that. There is no way I would have raised my hand and said "I am disabled" -- because I wasn't. The government is promoting the idea of "victim-hood." What a negative concept. If someone is blind or deaf or burdened with some similar disability, it is one thing. But to "get points" because you're a cancer survivor makes no sense at all.

Many jobs cannot be done by the disabled. What are these companies supposed to do? I thought that was what disability ben efits were for.Costs will now be passed onto consumers. We all pay. This administration has got to go. All Democrats = liberals have got to go.

Goofy rule. Just sounds like the employer will encourage their workers to self-report themselves as disabled. Once everybody understands the "game," you'll just see an explosion of "disabled" workers and employers will meet their quotas.

Nothing wrong with that Peter. In fact, that is exactly what is needed, isn't it? You being hired because of what you can contribute. You should not be barred because you are disabled or given a job just because you are disabled. ADA already takes care of the former.

What are the new rules trying to accomplish? I think that is Jeffery's point. These are rules that force a segment of population's employment to be dependent on what the govt. thinks is right and not by their contribution capacity.

Peter, there's nothing wrong with hiring someone with a disability as long as it doesn't affect their ability to perform the tasks required. What IS wrong is mandating that a percentage of your employees must be disabled. What happened to the notion of hiring the BEST PERSON for the job? If that person happens to be disabled - then hire them. If that person happens to not be disabled - then hire them.

The problem is that disability is sinking medicare. The problem is that people that were laid off realized that they could get disability along with other government aid and be almost as well of as they were before and don't need to show up for work.

Great! It took us a few decades to get to be treated as equals and now this administration is hell bent on tagging us as second class citizens and taking away our self respect. Plenty of people adapt, use devices and other support mechanisms to lead as normal a life as possible. It sucks to have a disability. It comes with its own set of physical and social challenges. It sucks more to be labelled as disabled which is synonymous with inferior/dependent. Disability does not necessarily mean dependency. With this policy in place how many years will it be before anyone with a disability in a good position be automatically assumed as having received special favors?

If the administration really has the well being of disabled at heart, it should proactively encourage policies that accelerate medical and technical innovations which help the disabled lead a normal life. I am sure that such policies will also result in innovators usable by society at large and not necessarily benefit just the disabled, a win-win.

Hmmm, how will the statistics be validated? My employer can ask if I am disabled and I can say "yes, no, or I prefer not to answer", but if I answer in the affirmative, the employer does not have the right to ask about the nature of my disability.

If the employer cannot ask me, and certainly not my doctor, about my disability and it is not an obvious disability under the ADA, how would the DOL determine if the reported statistics for a given company were accurate?

Is the DOL going to have the names of the individuals who are "disabled" and if they do, is it their plan to contact the employees and/or care providers to ascertain the validity of the claimed disability?

There are often ways for companies to get around it. I worked as a consultant for a company and when the project was finished there was another opening. However, the company had a long standing requirement that permanent employees had to have a current driver's license (not state ID). Since I have epilepsy, I cannot get a driver's license so I was not able to apply for a job I had been doing.

As a disabled professional who wants to work to the best of my abilities, I support stronger regulatory and legislative pressure on employers to hire the handicapped. I was laid off by my employer a year ago due to not being able to work a full 8 hour day under intense pressure and at full speed. My employer flatly refused to invest in the accommodations I needed, saying that they were not reasonable from an economic standpoint. However, if there were government-enforced fines for such behavior, loss of charitable non-profit status for hypocritical organizations which are actually only concerned about their own bottom line, and stronger incentives such as tax breaks for accommodating the disabled, then the economic scales might tip in favor of hiring persons like myself.

Actually, since few government contractors, except perhaps those working HHS contracts, will be growing payroll and DoD contractors will be eviscerating their payrolls with at least the same vigor that the Democrat Party is disestablishing the nation's defenses, the only way companies that don't happen to already have the necessary quota will be to eliminate employees that do not qualify to replace them with ones that do. Since thy're not going to be able to eliminate employees that are members of other protected classes, it becomes obvious how they have to draw up their lists of who needs to go.

"If an organization refuses to engage in charitable activities, as defined by our elected representatives, why should it be granted tax-exempt status? Why should..."

I think you are asking very interesting questions, but none of them are really relevant to the questions we've been discussing thusfar. I understand your thesis, David, which is that a "tax exempt" organization receives benefit from the public from its classification and therefore should convey some sort of public benefit. What I think you're failing to acknowledge is that hiring you to do the job you want to do at the pay you want to earn even though you can't do the job productively is not a public benefit at all. It's just a benefit to you. Being disabled doesn't make your personal welfare into public welfare.

On a philosophical level, I see no distinction between your insisting that your prior employer make a number of unprofitable investments and accommodations so you can continue to work at a job you cannot do well, and my insisting that a major league baseball team hire me as a pitcher at league average salaries and elevate and move the mound closer to home plate so I can pitch effectively.

Chris, you hit the nail right on the head... This is America under Obama. Never mind the economic growth is stuck at frustrating low gear, never mind that the over employement rate is subbornly high, never mind that we are losing our competitiveness to China, India, Korea, etc... Let's make sure each employer hire exactly 7% disable, 5% of people over 7 foot tall, 3% with reading disorder, 21% over weight... You get the point - this is liberalism at its worst form. Thanks a lot to you Obama voters out there.

That's too bad. Guess you were not in NY city, as a few people there walk, take the subway, occasionally take a taxi or bus, and do not know how to drive. It is expensive to park a car in NY City (many hundreds of dollars to rent a space in a garage).

Same might hold for a few smaller cities to a lesser degree - not sure that everyone in Washington DC knows how to drive. (Not being sarcastic - a few young professionals who bike, walk, take subway - do not drive.)

Can a company really require a driver's license? Might be illegal on their part. Could you siggest they are unreasonable - not file a lawsuit, but talk to management?

I've been there myself. You need to approach the Equal Employment Opportunity Commission (EEOC). They should be able to steer you in the right direction. To everyone who claims that you are acting with ulterior motives--I've had to face the jeers of the ignorant (I have a non-visible disability) but in the end I was able to get a job again.

"You should be protesting all of those forms of corruption, that funnel the big bucks to the big boys...."

David, I take issue with all the crony capitalism we're dealing with these days, but that doesn't justify your position. At least we're getting a little honesty now. I think it's fair to say now, given your recent statements, that your prior statements about wanting to "give back" etc. were disingenuous. You just have your hand out like the other cronies, trying to get it in other peoples' pockets.

I'm sorry about your disability, David. I think society should make reasonable provision for people with disabilities. I'm not sure that provision means being just as well off as you would be if you hadn't become disabled, and such provision should not disincline them to find other ways to be productive and lessen their burden on the rest of us (as I suspect has unfortunately been the case with you based on your comments above). But your position is pure self-interest masquerading as populist mush.

David, I'm curious, did you at least offer to reduce your salary/wages to reflect your slower pace of work and your inability to work a full day's work and to allow your employer to recover the cost of improvements needed to accommodate you, so that the employer wasn't losing money by using you?

Obviously, insisting on being effectively paid more per unit of output than your coworkers will tend to make you unpopular in the employer's eyes. Or maybe it's your view that the employer should reduce salaries for all to recoup his costs, so essentially your coworkers are paying for it?

"Are you an attorney, Carl? If you are, and wish to consider taking my case on a contingency basis, I would like discuss this further with you. If you are not an attorney, you should not be giving legal advice."

In other words, there's more to this than you are letting on. Thought so...

" .... due to not being able to work a full 8 hour day under intense pressure and at full speed ..... "

And that really is the issue. The employer expects (and is entitled to expect) to get a full day's work from paid full-time employees and pressure is part of life (and relative). I'm truly sorry that you were unable to reach a part-time arrangement or a mutually agreed upon accomodation/upgrade full-time arrangement. But your former employer's expectations are not "unreasonable". Are you routinely willing to pay 100% of a tab and receive less than the 100% of services contracted for in return.

" ..... hypocritical organizations which are actually only concerned about their own bottom line .... "

The hypocrisy is yours. Every organization MUST be concerned about their own bottom line, even charitable non-profits, if it has any interest in continued operations. One cannot run in the red indefinitely - unless one is the government and can simply print money. Being a non-profit does not make the organization exempt from the basic laws of mathematics, accounting and solvency.

I do hope that you are able to find a position that suits both your and your employer's needs. Better yet, start your own business and then you can make your own rules and decisions.

Even if your former employer IS an "unreasonable" @$$h0l# ....... that still does not make you "right". Employment is a mutually agreed upon contract between two parties, both of whom have expectations that need to be met for success.

And your point is.....? The WSJ is a journal of news & opinion. I did not write my comments to elicit employment advice, sympathy or compliments. My purpose was to express support for recent measures taken by the government to promote employment fairness for the disabled, knowing that this forum would be biased against those policies. I am more interested in whether you agree with me, or if not, why not, than I am in your advice, given that you are not privy to my personal situation. But thanks for your good intentions.

You said it! All the government cares about is that you're following the "Rules to Utopia" playbook - with the rules set by the Government. Almighty Leviathan will determine what the "correct" mix of your employees (and customers) will be, what markets you'll be in and, of course, what outrageous taxes you'll pay to support that Utopian dream society. The fact that their model has utterly forgotten to take things like profits, human nature and free will (which Leviathan is trying to beat out of us) into account, a necessity for all non-government enterprises, won't matter. They'll just keep tweaking the model until the whole system breaks down and we've completely lost the economic dynamism that America used to exemplify.

My suggestion that the gentleman with epilepsy should be provided with a limousine was an example of a rhetorical device known as "hyperbole" and should not be read while wearing your "literal" glasses. Do you have a pair of "figurative" reading glasses? Try re-reading my comment while wearing those.

I don't understand the basis for the conclusion that society is better off to provide somebody limousine service if needed to do "their job." Maybe it's true. Maybe it isn't. It depends on the facts. Certainly, society is not better off to have limo service bring somebody to work each day to do a minimum wage job. The cost of the service is probably far in excess of the value of the labor contributed, such that society is probably better off just paying them their minimum wage to stay home.

I think if somebody becomes disabled such that they cannot do "their job" productively (meaning there's no acceptable wage at which that person could do the job that somebody else would want to hire that person to do it), society would be best off if that person changed to a different job that they could do productively. The best indicator of whether you can do a job productively is that another person will hire you to do it without special incentives or subsidies. And the jobs you can do most productively are generally the ones you'll get paid the most to do.

We could separately discuss whether the person who becomes disabled should be compensated for any loss of income resulting from having to change jobs or reduce pay to allow them to function productively with their disability. The answer on that question does not change the fact that society is best off if people find the jobs they are most productive at doing under their present circumstances -- not the jobs they most like doing.

It's funny how people seem to think they have a right to not have their life altered by events, and that society should adjust to allow them to live as they have before. In this case, it seems from your post above that society is taking good care of you and you feel no particular urge to find a job outside your chosen profession. If you can't work in that job, you're content to collect disability whilst grousing about your employers and the "bean counters" unwillingness to spend money to let you do the job you want to do. That doesn't sound like somebody who wants to "give back." That sounds like somebody who wants somebody else to "give them."

Good points all, John, worthy of a learned free-marketeer. Unfortunately, there are no free markets any more. They have all been regulated and corrupted and insider-traded out of existence. Currencies and markets are manipulated for the benefit of those who work the levers of power. America's campaign finance system is the most blatant form of baksheesh which exists on this earth. The government selectively enforces laws to the benefit of their political allies and to the detriment of their political opponents. You should be protesting all of those forms of corruption, that funnel the big bucks to the big boys (and girls). It seems mean-spirited to want to establish the only truly free market in this formerly free country by making the disabled compete on an "equal footing" with those lucky enough to be healthy. Go argue with the billionaires who are bribing elected officials with surprisingly small campaign donations to buy favorable regulatory treatment and no-bid contracts and selective non-enforcement of arbitrary and voluminous regulations that benefit the corrupt rich. When you are all done with that, then come back and settle your score with the handicapped. Until then, let us keep our jobs so we can pay our taxes and complain about it like everyone else.

Brian, may I request that you elaborate? You say that you "take the opposite position", but you do not specify which of my statements you are discussing. The statement I wrote immediately before your post was to advise a woman who had just called me a stupid hypocrite (without any explanation or elaboration, and in violation of the Wall Street Journal's rules against baseless character assassination) the following regarding LIbertarian Party meetings: "Incidentally, if you are a single woman who is interested in meeting eligible men, that would be a good way to do so." If that is the opinion of mine to which you take the opposite position, then kindly explain what advice you would give a woman who has nothing better to do than to drop a brief, cryptic insult bomb into an intellectual discussion among WSJ readers?

Well, I hope that you do not include former Libertarians in those categories. If you attend a Libertarian party meeting, as I did several times, you will realize that they are not "stupid", in fact many of them are engineers with advanced degrees. Nor are they "hypocrites" because they are hard-working tax-payers who advocate what they truly believe in. On paper, from a mathematical point of view, their theories are quite elegant and convincing. I would suggest that the best way to convince them that they are wrong is to attend their meetings and engage them in polite debate which does not include name-calling. Incidentally, if you are a single woman who is interested in meeting eligible men, that would be a good way to do so.

"I would like to give back through gainful employment in my profession"

David, I think it is important that you understand that to the extent you gain employment through federal mandates and incentives, you're not really "giving back" to anything. You're still losing society money. The incentives just cause the societal loss to be "socialized" so everybody earns a little less to make room for you on the assembly line and the loss is less apparent to you. This may make you feel better because you're working and the loss isn't as obvious to you and all around you, but it's an illusion.

If you really want to be productive, then you need to find a way to earn an income that does not require incentives, because that's the only way you can actually be sure you're contributing to the societal bottom line. Unfortunately, that may mean looking outside your preferred profession. But certainly one who truly wants to "give back" would not insist on limiting oneself to a given profession.

My case is actually very transparent. If I had not been stricken with a chronic progressive disability, I would still be working hard every day at the profession I love, perhaps helping people like you. The minute it became uneconomical to employ me, I was discharged. Without getting into specifics, I learned that it is not by any means easy to take these matters to court, especially if one's damages are ameliorated by disability insurance, both public and private. My point is that, while society takes good care of my needs at this time, I would like to give back through gainful employment in my profession, and the only way that is going to happen is if the government creates strong incentives for employers to hire the handicapped. If you are a free-market guy, it can be tax credits for investing in accommodations which are required for the disabled to do their jobs. If you are a big-government fan, as I am starting to become, it can be through fines and regulations which force the hypocrites in high places to walk their talk.

By the way, this former Libertarian has nothing but good things to say about ObamaCare so far.

David, there is something incoherent in your comment. If you were a free-market libertarian it is hard to comprehend that you could ever see yourself as working for society. Why did your accident convince you that you must? You write that you are unpaid and I believe you. But isn't that your choice given your new philosophy and isn't your lack of pay consistent with that philosophy as well?

That the CEO of the charity makes $3M is clear evidence that he/she isn't doing it for society. You might want to rethink things.

Jennifer, I was a free-market Libertarian before I became disabled. Now I see matters from a different point of view. I work very hard every day for the benefit of society, but unfortunately I am not paid one penny for my efforts. Meanwhile, the CEO of the charity which fired me for being disabled earns $3 million dollars per year. I'm just saying that organizations like that should lose their tax-deductible charity status. If they don't want to help society by hiring the handicapped, then they should not expect society to perpetuate their tax-advantaged status.

And, by the way, I did offer to work part-time, an offer which was refused despite eligibility for subsidies for the cost of my accommodations.

Are you an attorney, Carl? If you are, and wish to consider taking my case on a contingency basis, I would like discuss this further with you. If you are not an attorney, you should not be giving legal advice.

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